Side by side
Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Company · Germany
Industry association · Italy
Declared costs: €500K+ a year · in the register since 2008
Simplifying and reducing the burden of the rules on medical devices and in vitro diagnostic medical devices, and support of the European Medicines Agency for the expert panels on medical devices and the list of Union harmonisation legislation · Digital labelling of EU fertilising products
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
orochemie GmbH + Co. KG · filed 1 Oct 2025 · source
One of the problems with the MDR is the extremely high cost of certification and the assessment of technical documentation. The costs have at least doubled since the switch from the MDD to the MDR. The significant increase in external costs is due to increased internal costs due to the increased documentation burden.
Filed in German · English published by the European Commission
Federchimica · filed 1 Oct 2025 · source
Dear Members of the Commission, Assogastecnici, part of Federchimica, is the association of companies active in the production and distribution of technical, specialty, and medicinal gases. Its member companies represent the entire national market and employ approximately 5,000 people, generating a turnover of approximately 2.6 billion.
orochemie GmbH + Co. KG · filed 20 Sept 2021 · source
A clear simplification of the labelling rules would be the legalisation of multilingual folding or tag labels in times of globalisation. Multilingual folding/tow tags in all EU languages would: — simplify supply chains; — support sustainability (saving of air-conditioned storage areas, etc.) — shorten transport routes (the same product can also be sent to and used in a neighbouring country) — Promote the free…
Filed in German · English published by the European Commission
Federchimica · filed 20 Sept 2021 · source
The Italian Federation of Chemical Industry strongly welcomes this initiative from the European Commission. Simplification and digitalization can contribute to improving efficiency, efficacy and safety. There are many advantages that it’s necessary to take into account: • Digitally stored labelling texts can be updated promptly.
Federchimica · filed 29 May 2023 · source
AssoFertilisers, the National Fertilisers Association, which is part of Federchimica-Confindustria, brings together the main Italian fertiliser operators, with a total turnover of around EUR 1 billion, representing over 90 % of the Italian market.
Filed in Italian · English published by the European Commission
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